• Should Your Nursing Home QAPI Program Be Updated Annually?
  • August 11, 2016
  • Law Firm: Weltman Moskowitz LLP - New York Office
  • The Affordable Care Act, which was signed into law in 2010, requires nursing homes to have effective Quality Assurance and Performance Improvement programs (QAPI) in place within a year of the passage of QAPI regulations.1 "QAPI is the merger of two complementary approaches to quality management, quality assurance and performance improvement,"2 according to the Centers for Medicare & Medicaid Services.

    Because nursing homes themselves are best suited to assess and evaluate their individual care and services, QAPI programs must be implemented - and re-evaluated - by each nursing home.3 Quality assurance ensures that the standard of care reaches an acceptable level,4 and performance improvement is aimed at advancing processes involved in healthcare delivery and residents' quality of life.5

    The QAPI process encourages employees at all levels of the organization to:
    • Identify opportunities for improvement;
    • Address gaps in systems or processes;
    • Develop and implement an improvement or corrective plan; and
    • Continuously monitor the effectiveness of interventions.6
    Five elements of an effective QAPI program:
    • Design and Scope
    • Governance and Leadership
    • Feedback, Data Systems and Monitoring
    • Performance Improvement Projects
    • Systematic Analysis and Systematic Action7
    Design and Scope address the need for a QAPI program to be ongoing and comprehensive, while dealing with the full range of services within the facility.8 It will always include clinical care, quality of life, and resident choice.9 Governance and Leadership address the nursing home's governing body and/or administration's development of a culture that involves feedback from staff, residents and their families; and/or representatives of those residents.10

    Who Should Oversee the QAPI Program?
    At least one or two individuals should manage the QAPI program.11 Those individuals will set expectations around safety, quality, rights, choice and respect by balancing safety with resident choice.12 The Feedback, Data Systems and Monitoring element "includes using performance indicators to monitor a wide range of care processes and outcomes, and reviewing findings against benchmarks and/or targets the facility has established for performance."13 Reports need to be reviewed to assess what can be done to enhance QAPI, as well as what might be missing.14

    How Do PIPs Help Nursing Homes?
    Performance Improvement Projects (PIPs) are concentrated efforts that identify particular problems within a nursing home environment, and subsequently, prompt the creation of a plan of attack for correcting them.15 Staff must be encouraged to identify known issues and these area(s) could be improved. Every PIP will vary depending on the type of facility and the services they provide.16 Systematic Analysis and Systemic Action is the process by which "The nursing center uses a systematic approach to determine when in-depth analysis is needed to fully understand the problem, its causes, and implications of a change."17 It focuses on continual learning and improvement.18

    Implement an Effective QAPI Program Today
    It is paramount that every nursing home implements a QAPI program with the aforementioned five elements in mind, and continually monitors that program for improvement. Employees at every facility should review and update their QAPI program on an annual basis. In addition, data should be reviewed and analyzed at least quarterly to see how facilities' QAPI programs can be improved. Routine staff meetings can address possible improvements to the program. Each QAPI program will differ based on the services and care provided, but an effective program will ensure that patients' needs are identified and routinely addressed in an effective manner.

    1 https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/QAPI/Downloads/QAPIAtaGlance.pdf last visited July 17, 2016. See also https://www.ahcancal.org/quality&under;improvement/qapi/pages/default.aspx ("Section 6102(c) of the Affordable Care Act requires that all skilled nursing care centers develop Quality Assurance and Performance Improvement (QAPI) programs. The statute requires the Centers for Medicare & Medicaid Services (CMS) to develop a prototype QAPI program, establish standards, and provide technical assistance to centers on the development of best-practices in order to meet such standards. One year after a final rule for QAPI is issued, all nursing centers must have in place and implement an acceptable QAPI plan.")
    2 Id.
    3 Id.
    4 Id.
    5 Id.
    6 Id
    .
    7 Id.
    8 https://www.ahcancal.org/quality&under;improvement/QAPI/Pages/DesignScope.aspx last visited July 17, 2016.
    9 Id.
    10 https://www.ahcancal.org/quality&under;improvement/QAPI/Pages/GovernanceLeadership.aspx last visited July 17, 2016.
    11 Id.
    12 Id.
    13 https://www.ahcancal.org/quality&under;improvement/QAPI/Pages/Feedback.aspx last visited July 17, 2016.
    14 Id.
    15 https://www.ahcancal.org/quality&under;improvement/QAPI/Pages/PIPs.aspx last visited July 17, 2016.
    16 Id.
    17 Id
    .
    18 https://www.ahcancal.org/quality&under;improvement/QAPI/Pages/SystematicAnalysisAction.aspx last visited July 17, 2016.